can I also create a battery passport if I only sell a few hundred units

Also mandatory for a few hundred units

Yes, a battery passport can also be created for small batches, and the obligation makes no distinction between an importer who sells tens of thousands of batteries per year and an importer who brings a few hundred units to the market. Regulation (EU) 2023/1542 (Battery Regulation), Article 77 links the obligation to the type of battery and its capacity, not to the size of the batch. A small batch therefore does not mean that the passport can be skipped — it mainly means that the costs and effort per unit are higher, because setting up a passport is largely fixed work, regardless of whether it concerns two or two thousand units.

Where the line is drawn: type of battery, not the batch size

The obligation applies to EV batteries, batteries for light mobility devices (such as e-bikes and scooters) and industrial batteries above 2 kWh. For those categories, it does not matter whether it concerns a one-off import of a new model or an ongoing product line: as soon as a battery falls within one of those categories, the passport obligation applies to that model. What does play a role is the number of different models: an importer with five models in small batches has more work in practice than an importer with one model in a large batch, because each passport is linked to a specific battery model and not to a sold unit as such. Anyone in doubt about whether a particular type of battery actually falls under the obligation will find the delimitation between what does and does not count on the page about whether the battery passport applies to a specific battery.

Where the obligation does not apply: consumer batteries such as individual AA or AAA cells, and batteries that fall outside the mentioned categories or remain below the indicated capacity. Those batteries are subject to other rules from the Battery Regulation, but not to the passport obligation of Article 77.

From 18 February 2027, with no transitional provision for small volumes

The obligation enters into force on 18 February 2027, as laid down in Regulation (EU) 2023/1542, Article 96. That date applies to all batteries within the designated categories that are placed on the market from that moment on — there is no separate transitional period or exemption for small batches. Until that date there is no legal obligation to have a passport yet, but batteries that are placed on the market for the first time after 18 February 2027 must have one, no matter how small the batch is.

For batteries that are already in stock before that date or have already been sold, different considerations apply; what exactly applies to that is described on the page about batteries already in stock before the obligation enters into force.

How a small batch is handled in practice

For a small batch, the first step is the same as for a large one: determine whether the battery falls within the categories of Article 77, and if so, which data from the manufacturer or supplier are already available. Especially with small batches, it is worthwhile to check in advance what a passport costs in relation to the turnover of that batch, because part of the costs (assembling and hosting the passport) is fixed per model and not per unit. An overview of what is involved financially is on the page about the costs of a battery passport.

After that it is practical to plan how much time it takes to get all the data in order — with a small batch this is often less work than with a product line with many variants, but the steps are the same. An indication of the process is on the page about the time required to put a battery passport in order. Next, the passport and QR data carrier must be linked to the correct model and tested before the batteries are actually sold — even with a small batch, a passport that does not work properly is just as much a problem as with a large shipment. A concrete approach for setting up a passport step by step is on the page on setting up the battery passport step by step.

The basis: Article 77 and Article 96 of the Battery Regulation

The obligation to have a battery passport derives from Regulation (EU) 2023/1542, Article 77, which designates the categories of batteries for which a passport is mandatory: EV batteries, batteries for light means of transport and industrial batteries above 2 kWh. That article contains no minimum threshold for quantities or batches. The entry into force date of 18 February 2027 derives from Article 96 of the same regulation, which governs entry into force and application. Both articles can be consulted via the official text of the regulation on EUR-Lex; background information on the regulation as a whole can also be found at the European Commission on its page on batteries and accumulators.

Those who, after reading this page, wish to check whether a specific battery falls within the obligation should start with the delimitation on the page on whether the passport applies, and work through the cost and time estimate from there before the actual implementation is planned.